Comment submitted by B. Price

Environmental Protection Agency Office of Pesticide Programs (OPP) 1200 Pennsylvania Avenue, NW Washington , DC 20460-0001 Docket ID Control Number OPP 2005-0162 Re: Furadan on Cotton Over the past 40 years I have consulted on row crops in Mississippi. I have owned my own business, Price Agriculture & Entomology Service, Inc. , for 38 years. My son received his Master degree from Mississippi State University in 2002 in Entomology and Plant Pathology and joined the business. We take care of cotton, corn, soybeans, sweet potatoes, and wheat in Tallahatchie, Panola, and Quitman counties. Cotton is our main crop and we service over 24,000 acres and 34 farmers. Cotton is a high input crop with seed, fertilizer, fuel, chemicals, and technology fees rising each year. It is a challenge for farmers to make a profit and stay in business. In the area we work farmers plant over 80% GMO seed. This technology is not cheap and will get more expensive with newer technology coming down the pipeline. Example: Bollgard II/Flex, Widestrike/Flex or Flex alone the stacked varieties are $65.00 to 70.00 dollars per acre. I am sure most of you are aware that when BT Cotton was introduced in 1996 it did a great job on resistant Tobacco Budworms. Now that we are not making multiple applications to control this pest we are seeing a shift in the pest population. The so called ?secondary pest? such as plant bugs, mites, aphids, white fly and armyworms have moved to the forefront. In my business we have always tried to use a good pest management approach. We try and alternate chemistry as much as possible. The problem with this type of program is that we do not have much new chemistry available to us. The real concern is not many companies are working on new chemisty to control this pest. In Mississippi our research group at Stoneville has documented plant bug resistance to pyrethroids and organophosphate materials. We are now seeing problems with the neonicotinoids not controlling aphids. We are using maximum rates to try and control plant bugs and aphids. These neonicotinoids are not cheap when used alone and if you tank-mix these products with a product like Diamond (IGR?S), the cost per acre can double. Example: 2 oz. Centric alone - $8.00 to $8.50 per acre 2 oz. Centric + 6 oz. Diamond - $ 14.00 to $ 15.00 per acre The past few years aphids are becoming harder to control and much more expensive to the farmer without the use of Furadan. In years past where Furadan has been available we have only had to use it one or two applications season long. I can remember using only one application to ?crash? aphid populations. The past year we had to wait on the fungus to take out aphids and some farms did not get rain to take the honey dew and mold off the plant. The grower had to deal with sticky cotton, wrapped spindles and grade issues. Furadan is a product I feel could fit well into our Insect Resistance Management program and save our farmers a lot of money in the process. In the past Furadan has been priced at $4.00 per acre, and if used alone is a $4.00 savings over a full rate of neonicotinoids. In 2006 the final planted cotton acres in Mississippi was 1,210.00. At $4.00 per acre that is a savings of $4,840,000.00 on one application. If you start adding discounts for grades, due to mold on the lint, down time with a six row cotton picker, and dealing with ?sticky cotton?, the cost to the farmer continues to climb. Mills are starting to demand higher quality cotton and Furadan could easily solve some of the issues our farmers face during harvest and make possible the sale of a quality cotton crop. I am writing on behalf of my company and the farmers we service. I am not writing formally on behalf of our Mississippi Agricultural Consultant Association but I have talked to many of our members and many see the need for the use of Furadan. I know that I can honestly say for me and for many MACA members that if we get this product back, we will be good stewards of this product. Best regards, Bill Price, Jr.